Julia Marsh

Thank you for your reply. My point is that surely the current tax treaty in force is the version that has been applied from 1st January 2024, which states that Withholding Tax on dividends, other than that derived from immovable property or REITs, has been reduced to 0%. My dividends are not from immovable property or REITs and yet 15% is still being deducted. I do not see how this is correct - see below:- https://www.gov.uk/government/publications/luxembourg-tax-treaties/uk-luxembourg-double-taxation-convention-and-protocol-not-in-force Article 10: Dividends Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State. However, dividends paid by a company which is a resident of a Contracting State may also be taxed in that State according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State: a) except as provided in sub-paragraph b), such dividends shall be exempt from tax in the Contracting State of which the company paying the dividends is a resident; Sub paragraph b) does not apply since it only relates to income derived from immovable property or REITs, which my dividends are not.

Re: Luxembourg withholding tax on dividends On 19th July 2023 the Luxembourg Parliament ratified the updated UK-Luxembourg Double Taxation Agreement, whereby Withholding Tax on interest, royalties and dividends was reduced to 0%, other than for REIT Property Income Distributions which the treaty reduces to 15%. With the UK government having already ratified the new treaty, this change was applied from 1 January 2024. However, the dividends in B&M European Value Retail SA that were paid to me on 12th February 2024 and 5th August 2024 have both continued to be paid net of 15% tax. Correct me if I am wrong, but I assumed that from 1st January 2024 dividends in Luxembourg listed companies would be paid gross to UK beneficiaries, and any dividend tax due would be paid at UK dividend rates and calculated in our tax returns. Am I able to reclaim the 15% tax on these dividends, as my taxable income is less than the personal allowance, and is there any way to have the B&M dividends paid gross in the future? Many thanks.